Human Resources
The Washington Report - 2/21/2018

The Washington Report

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February 21, 2018


Departments Release Proposed Rule on Short-Term, Limited-Duration Insurance

On February 20, 2018, the Departments of Labor, Treasury, and Health and Human Services (the Departments) released a proposed rule amending the definition of short-term, limited-duration insurance for purposes of its exclusion from the definition of individual health insurance coverage. This action is being taken to lengthen the maximum period of short-term, limited-duration insurance. In October 2017, the President issued an Executive Order instructing the Departments to consider proposing regulations or revising guidance to promote healthcare choice and competition by expanding the availability of short-term, limited-duration insurance. The latest rule, as a result of the Executive Order, would change the maximum duration of such coverage to less than 12 months, as opposed to the current maximum duration of less than three months.

Short-term, limited-duration insurance is a type of health insurance coverage that is designed to fill temporary gaps in coverage when an individual is transitioning from one plan or coverage to another form of coverage. This type of coverage is exempt from the definition of individual health insurance coverage under the Affordable Care Act (ACA) and is therefore not subject to the ACA provisions that apply to individual health insurance plans. The proposed rule includes measures to help consumers who purchase short-term, limited-duration policies understand the coverage they are getting. The proposal would require one of two versions of a notice to appear in the contract, and in any application materials, that the plan is not required to comply with ACA provisions. Comments on the proposed rule are due by April 23, 2018.

A fact sheet is available here.

The proposed rule is available here.

Aon Publications

Update: 2018 Aon Compliance Calendar—Significant Compensation and Benefit Due Dates
<This bulletin has been updated.>

Aon is pleased to present its 2018 Compliance Calendar to help plan sponsors identify significant compensation and benefit due dates for retirement and health and welfare plans. This Compliance Calendar includes relevant dates involving plan disclosures, contribution and distribution requirements, and various plan-related regulatory filings.

This Compliance Calendar assumes a plan administered on a calendar year basis by an employer with a calendar fiscal year. In general, the information for pension plans applies to single employer plans; other plans, such as multiemployer plans (e.g., Taft-Hartley plans) or government plans, may be subject to different requirements, and are not included. Additionally, certain compliance dates related to group health plan coverage or retiree prescription drug coverage have been included where applicable.

The Compliance Calendar is intended to alert the reader to some of the more significant dates for 2018 and is not intended to identify all compliance obligations or due dates.

The 2018 Aon Compliance Calendar is available here.

Medicare Dollars and Donuts: Budget Act Repeals Independent Payment Advisory Board and Starts Closing Medicare Part D “Donut Hole” in 2019

The Bipartisan Budget Act of 2018 (BBA) signed into law by President Donald Trump repeals a major cost control provision of the Affordable Care Act, revises the contribution structure in Medicare Part D, and increases premiums for high-income Medicare beneficiaries.

A brief summary of the BBA’s changes is provided here.

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